Casper v. Dhl Global Customer Solutions (Usa), Inc. et alMOTION for Summary JudgmentD. Mass.June 29, 2017 1 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS __________________________________________ ) ROB CASPER, ) ) Plaintiff, ) ) v. ) Civil No. 1:16-cv-40035-NMG ) DHL GLOBAL CUSTOMER ) SOLUTIONS (USA), INC. and DHL GLOBAL ) CUSTOMER SOLUTIONS AND ) INNOVATIONS (USA), INC.., ) ) Defendants. ) ) DEFENDANT DHL CUSTOMER SOLUTIONS AND INNOVATIONS (USA), INC.’S MOTION FOR SUMMARY JUDGMENT Pursuant to Fed. R. Civ. P. 56, Defendant DHL Customer Solutions and Innovations (USA), Inc. (“DHL CSI” or “Defendant”) hereby moves for entry of summary judgment on all of the claims asserted by Plaintiff Rob Casper. For the reasons set forth in the Memorandum of Law in Support of Defendant’s Motion for Summary Judgment, filed herewith, summary judgment should enter because, on the undisputed facts, there is no dispute of material fact and DHL CSI is entitled to judgment as a matter of law. In addition to their supporting memorandum of law, Defendant relies on its LR 56.1 Statement of Undisputed Facts and the Affidavit of Anthony C. White, both filed herewith. REQUEST FOR ORAL ARGUMENT Pursuant to LR 7.1(D), Defendant requests oral argument, as it believes argument may assist the Court in its consideration of the issues presented by this motion. Case 1:16-cv-40035-NMG Document 39 Filed 06/29/17 Page 1 of 3 2 Dated: June 29, 2017 Respectfully submitted, DHL CUSTOMER SOLUTIONS & INNOVATIONS (USA), INC., By its attorneys, /s/ Alan D. Rose o Alan D. Rose (BBO #427280) Matthew C. Steinberg (BBO #691003) One Beacon Street, 23rd Floor Boston, MA 02108 Tel: (617) 536-0040 Fax: (617) 536-4400 adr@rose-law.net mcs@rose-law.net Anthony C. White (admitted pro hac vice) THOMPSON HINE LLP 41 South High Street, Suite 1700 Columbus, OH 43215 Tel: (614) 469-3235 tony.white@thompsonhine.com Case 1:16-cv-40035-NMG Document 39 Filed 06/29/17 Page 2 of 3 3 CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7.1 (A)(2) I, Anthony C. White, hereby certify that on May 27, 2017, I notified Plaintiff’s counsel that Defendant intended to file a motion for summary judgment. As of the 5:30 p.m. (EDT) on June 28, 2017, we have not received a substantive response from Plaintiff’s attorneys that would permit the parties to narrow or resolve the issues presented in this motion. /s/ Anthony C. White o CERTIFICATE OF SERVICE I hereby certify that this document filed through the ECF system will be sent electronically to the registered participants as identified on the Notice of Electronic Filing (NEF) and paper copies will be sent via mail to those indicated as non-registered participants on June 29, 2017. /s/ Alan D. Rose o Case 1:16-cv-40035-NMG Document 39 Filed 06/29/17 Page 3 of 3
